The Ontario Federation of…

The Ontario Federation of Anglers and Hunters Foundation (OFAH Foundation) is dedicated to preserving Ontario's natural heritage through conservation research, habitat restoration, and educational initiatives that promote sustainable outdoor activities. As a leader in conservation, we work collaboratively with partners, experts, and communities throughout Ontario to protect and enhance fish and wildlife populations for today and future generations. We have reviewed “ERO 025-1257: Proposed boundaries for the regional consolidation of Ontario’s conservation authorities” and offer the following comments for consideration.

OFAH Foundation acknowledges the value of improved efficiencies and modernization in the context of today’s changing landscape. We are supportive of the general intent to eliminate unnecessary duplication and inefficiencies. However, the proposed model for conservation authority amalgamation and management appears to extend well beyond the bounds of normal and necessary improvements, proposing drastic and consequential action with insufficient justification or considerations for alternatives.

Posting discussion questions:

1. What do you see as key factors to support a successful transition and outcome of regional conservation authority consolidation?

Ontario’s CAs are internationally recognized for their use of natural watershed boundaries and, by extension, highly localized governance and oversight. Our province has set a precedent of accountability and expertise thanks to these unique, nature-based jurisdictions, and it is for this reason that OFAH Foundation does not support the plan for amalgamation as it is presented here. Despite wording around “align[ing] with hydrological boundaries,” the proposal to amalgamate all 36 of Ontario’s CAs into 7 massive authorities will shift decision-making authority away from local representatives, undermining local knowledge and expertise by diluting these voices in a pool of representation from other, very different regions. We are especially concerned that this will allow for disproportionate political influence on decision-making. Whether by outside stakeholders or as a result of political directive, regional control is very likely to result in poorer environmental and safety outcomes.

While this applies to standard conservation authority roles and responsibilities, the proposed changes could easily impact unique and often localized programs and partnerships. The OFAH’s own Invading Species Awareness Program (ISAP) works closely with many conservation authorities on critical invasive species management, research, and education. Current watershed-based authorities possess deep local knowledge that is critical for identifying emerging threats, planning targeted monitoring activities, and coordinating on-the-ground outreach. Centralizing decision-making at a regional scale risks weakening this localized expertise and could delay or complicate the quick response required for effective AIS management.

A regional centralization of power may also impact access and recreation in unpredictable ways. CAs own tens of thousands of publicly accessible acres across the province, many of which are open to hunting and fishing. If access and opportunity decisions become subject to a larger swath of influence, or if one CA is driven to align with the standards of others, we are concerned that opportunities may change.

2. What opportunities or benefits may come from a regional conservation authority framework?

Some degree of regional oversight or input may offer benefits for existing CA structures. We acknowledge, for example, that permitting fee inconsistencies for development projects and even recreation may be a source of dissatisfaction and confusion. Increased regional connectivity may also improve tool and knowledge sharing between authorities, municipalities, and their stakeholders.

However, it is not apparent that conservation authorities require such drastic changes as are proposed here. The above changes could, for example, be achieved through centralization of information and resources rather than the consolidation and redistribution of power. In our experience, Ontario’s conservation authorities have, even under the stress of insufficient funds, proven themselves more than capable of fulfilling their role as knowledgeable watershed managers.

To ensure appropriate transparency and accountability, we recommend the province perform a public cost–benefit analyse / efficiency study demonstrating explicitly where the current system’s failings lie and exploring all possible solutions.

3. Do you have suggestions for how governance could be structured at the regional conservation authority level, including suggestions around board size, make-up and the municipal representative appointment process?

We strongly recommend the province retain the current local-only board structure, with all current decision-making power, while exploring less intrusive ways to incorporate regional input into the process. Regional advisory boards or stakeholder committees, for example, could ensure localized expertise remains the primary driver for CA action, maintaining their current efficacy and accountability, while adding a direct line for regional insight and communication.

4. Do you have suggestions on how to maintain a transparent and consultative budgeting process across member municipalities within a regional conservation authority?

5. How can regional conservation authorities maintain and strengthen relationships with local communities and stakeholders?

Regional management would likely struggle to develop the same connections to local stakeholders that have been established by local CAs. The scale of the current, watershed-based system is such that members of the public and stakeholders can easily relate to their surrounding landscape and draw value. Local oversight and engagement are essential. Many of ISAP’s most effective aquatic invasive species (AIS) programs, including early detection and monitoring, rapid response coordination, and community outreach are successful because of the long-standing partnerships and operational support provided by local conservation authorities. The Invading Species Hit Squad, for example, relies on local coordination, facility support, and community relationships to conduct monitoring, fieldwork, and public education.

If the province was to add a regional element to the current system without sacrificing the standing and influence of local authorities, these elements of connection and trust could be maintained.

Conclusion
Conservation authorities represent one of Ontario’s most unique and effective conservation and public safety mechanisms. The development of this made-in-Ontario approach to watershed management is recognized across the world for its effectiveness and integrity. While changes for efficiency’s sake are not negative in their own right, given the province’s recent directions, we are not confident that decisions will be made in the best interest of local communities or environment under the proposed system. We urge the province to move forward under the advice and guidance of Ontario’s many capable conservation authority staff and local municipal representatives, maintaining localized decision-making, stable funding, and seamless operational continuity. OFAH Foundation is grateful for the opportunity to comment on this matter and welcomes any chance to work directly with the province on this and other land-use issues.